SOLAS Container Weight Verification - Frequently Asked Questions (FAQs)
What is the SOLAS Container Weight Verification Requirement?
The International Maritime Organization (IMO) has implemented a SOLAS amendment, or change to existing regulations, to require that containers and their contents must be weighed prior to loading. With up to 20% of TEUs shipped with an incorrect weight, the need for a revised SOLAS Container Weight Verification was clear.
The regulation began initial enforcment on July 1, 2016. A verified container weight or Verified Gross Mass (VGM) must be provided prior to loading a packed container onto a vessel in many locations.
What does the IMO Memo MSC.1/Circ.1548 state is occuring on 1 October 2016?
The IMO has issued a memorandum MSC.1/Circ.1548 that states that individual countries must adopt a logical approach to enforcement. A clause notes that the initial enforcement period is in effect until October 1, 2016. The memo is is not a softening or more lenient interpretation of enforcement. The October 1 date is simply noted as the closure date for any flexibility that may be allowed. On 1 October, it can be interpreted that full enforcement will begin as specified in the original regulation. It is also important to note that if a country has not published national legislation on the subject, the SOLAS amendment is still in force.
In which countries will the SOLAS Amendment for a verified container weight be applicable? Who enforces the regulation?
The SOLAS amendment applies to all IMO member countries and its three associate members. Each country will appoint a "competent agency" that is responsible to monitor compliance with the rules, perform checks and take legal measures as necessary. Click here to find an overview of country-specific information on VGM. Please note that even if a country has not published national legislation on the subject, the SOLAS amendment is still in force.
What is the purpose of the SOLAS amendment?
The SOLAS amendment was introduced to increase the safety of container vessels, improve vessel stability and reduce the incidence of collapsing container stacks. With an estimated 10% of containers noting an incorrect weight, the regulation is of particular importance for vessel operators as well as to individual nations to avoid potential environmental damage.
Who is responsible to provide a verified weight to the carrier?
The regulation clearly stipulates that the shipper is responsible, being further defined as the shipper noted on the Bill of Lading (BOL). Since this can also be the freight forwarder, clear agreements defining responsibility should be made. In the case of a consolidation, only the consolidator, which is not the original shipper, is in the position to provide a final weight.
The task to verify the weight can also be delegated to a third-party, such as a private weighing provider or a terminal operator. The cost for this service should be published by individual terminals, however terminals in some countries may not have capacity to weigh all containers.
What will happen if a verified weight is not provided?
If a verified container weight is not provided to the carrier and terminal operator, the container cannot be loaded. In some ports, containers will not be allowed on to the terminal without a VGM. Some terminals are proactively offering scales as an added service, however this should be viewed as a fall back solution and cannot be used for all containers. Carriers are introducing a VGM closing date and time, which is anticipated to be earlier than the existing closing. Despite requests from some companies for a single closing, the VGM closing appears to be an additional requirement.
How should container weight be measured?
There are 2 methods to weigh containers in the regulation:
- Method 1: Weigh the stuffed container using calibrated and certified equipment. Every country can determine what is considered certified equipment. For example, in the United States, the U.S. Coast Guard has noted that there are no strict requirements for the scales.
- Method 2: Weigh all packages and cargo items; including pallets, dunnage and other securing material to be packed in the container; and add the "tare" weight of the container to the sum of the individual weights using a certified method.
How does the second method work in practice?
It is expected that most shippers will leverage the second option detailed above. Still, there are some challenges to this approach such as:
- In some countries, the calculation method must be officially certified. Regardless the official certification, the requirements can also vary country-by-country. In addition, timely certification is an other concern.
- Variances in container weight may occur due to differences in environment or humidity. As a result, acceptable tolerances will need to be addressed. Many countries accept a tolerance of 5%, however many others still need to solidify their position on variances.
- Although the shipper needs to use the correct tare weight of the container, not all containers have the same weight. The weight stated on the door of the container should be used in theory, however there is no single database that contains all tare weights, although some carriers provide information tables for their own containers. As a proof of compliance, it has been proposed to take a picture of the container door and store the image digitally. In general, it has been confirmed by carriers that the tare weight on the container door can be used, and the shipper does not bear any responsibility for wrong tare weights on the container.
How should a verified weight be transmitted to the carrier and terminal operator?
One method to reduce errors is for shippers or freight forwarders/consolidators to transmit the information electronically to carriers. This data can, in turn, be further forwarded to the terminal operator.
In particular, the following data elements are to be transmitted:
- Unique VGM certificate identification
- Sender of the VGM data
- Container number
- Carrier booking reference number
- Terminal operator (optional)
- Shipper (optional)
- Verified Gross Mass
- Method used to determine the weight, Method 1 or 2 (optional, although some carriers request that this data should be provided)
- Responsible party (shipper on the BOL)
- Authorized party, delegated to verify the weight
- Date/time of the weighing
- Date/time of the VGM certificate
- Reference of the VGM declaration, especially in the case that it’s a separate message
- Shipper’s authorized person in capital letters. This is either the contact person of the responsible party or the contact person of the authorized party.
- Weighing party (optional), including a third-party such as a terminal operator
- Weight location (optional)
- Certificate information on the scale or Method 2 (optional)
What is a VERMAS message?
For communicating the VGM information to carriers, a new Electronic Data Interchange (EDI) message has been developed called Verified Gross Mass Message (VERMAS). This is the preferred communication protocol of many carriers, freight forwarders and shippers since this message is designed to contain all the required information including optional fields. The advantage of this methodology is to minimize the impact to the existing communication of shipping instructions. In addition, this process overcomes the challenge of expediting the shipping instruction deadline to meet the new VGM closing of the carrier. The VGM closing date is also added to the booking confirmation message.
Is there a form layout of the VGM certificate?
No, there is no formal layout for the VGM certificate. If all of the required information is contained on the form, it should be compliant. However, it is strongly advised to communicate the informarion electronically. Carriers are expected to charge a fee for manual submission.
What is the impact to existing applications and EDI messages?
Shippers and freight forwarders will have to adapt systems, such as Enterprise Resource Planning (ERP), Transportation Management Systems (TMS), Warehouse Management Systems (WMS) solutions and others to ensure that weight values housed in their system(s) are accurate. This is of particular importance when using the second method discussed above. The VERMAS protocol has been introduced to send data between various supply chain participants. In addition, some existing EDI messages may need to be adapted, such as the messages between the carrier and the terminals.
Descartes and the SOLAS Container Weight Verification Requirement
As a leader in regulatory compliance, Descartes is ensuring that our customers will be able to effectively transmit the required data elements in the right format at the right time. Customers using our solutions will be able to seamlessly move into compliance.
Descartes Verified Gross Mass™ (Descartes VGM™) - Descartes provides a SOLAS VGM EDI messaging service as the VGM functionality from our freight forwarding and transport management enterprise systems. The Descartes VGM solution offers an advantage by providing a single source to centralize processes from VGM, shipping instructions, bookings and more, and by providing a complete book-to-bill process.
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